Transferring The Witness’s Testimony To Your Client, Victor Balta, Esq Of Moss & Colella

As I promised, we would share more than just cross examination excerpts from my (Neil Rockind’s) cases.  Where another lawyer thought that he/she had some interesting cross examination, I would welcome their submission and comment on it.  Victor Balta, a personal injury associate attorney with Moss & Colella, PC, a personal injury and police brutality oriented firm in Southfield, Michigan, has done just that.

In a recent case invoking a slip and fall, one of the most decimated and difficult areas to practicing in given the Court’s hostility towards injured citizens, Balta used the witness’s testimony he was cross examining in order to attempt to establish that his client did have reason to look down at the sidewalk, the typical so-call, Open and Obvious defense.  Courts have been suggesting that you should look at your feet while walking instead of looking ahead — you may walk into traffic or others doing the latter (head down eyes to the ground) but the Court apparently thinks this is safer way to walk.  Most of the free world disagrees.

In this excerpt, Balta cross examined the opponent’s witness on this absurdity and then transferred that witness’ testimony to his own client — a cleaver and effective way to get the opponent to support your client’s position.  Here is the excerpt:

 Q. Is it fair to say that during the date of the
  incident, that you walked on the sidewalk a couple

A.   More than a couple, yes.

 Q.   Did you ever notice anything on the sidewalk that led
  you to believe that you needed to be careful or avoid
        certain spots of the sidewalk?

A.   No.

Q.   In your own personal opinion, are there any defective
 spots in the sidewalk that my client missed or should
 have avoided?

 [Defense attorney]:  Objection, form and

A.   No.

BY [Plaintiff attorney]:
  Q.   No, there’s no spots that [client] should have avoided,
 just to be clear?

A.   Correct.

From here, by taking the witness’ experience, Balta was able to tie it right to his client helping in establishing that the Open and Obvious is going to fail..  The opponent didn’t see anything and neither should have nor would have seen anything.  It was undetectable defect that caused Balta’s client serious injury.

What’s the lesson?  When conducting a killer cross examination, you don’t have to rely solely on our own witnesses in building your case.  Testimony from the opponent that supports your position or undermines the opponents.  Balta did just that here.  Well, Victor Balta, well done.

Victor Balta is an attorney with Moss & Colella, a personal injury and police brutality law firm in Southfield, Michigan.   Moss & Colella is to many fine lawyers including Super Lawyers Vince Colella and David Moss.  They can be reached at 248.945.0100 or at or or   If you want to contact Balta directly about this post or others contact him at and

Attorney Comments On Neil Rockind’s Cross Examination Of A Police Officer In Trial – Calls It “Classic”

UPDATE: the trial at issue resulted in an acquittal for our client:  he was acquitted of all charges, including Aggravated Assault and Assault and Battery.   Here are pictures of the complainant so that the reader can appreciate what we were up against:

Thompson Photo 3 Thompson Photo 2 thompson photo 1

In a hotly contested Aggravated Assault trial presently underway, veteran trial attorney Michael Hohauser has been intently observing the proceedings.  As trial started, Hohauser watched each step Neil Rockind took in the case.  Rockind is defending the accused and it will be Hohauser’s job to defend the same gentleman in a civil case that has been filed in which the complainant is seeking monetary damages.  Hohauser watched Rockind’s opening statement and his cross examinations of the three (3) witnesses to date:  the complainant, the complainant’s wife and the arresting officer.  During each and at times, the judge interfered sustaining some objections raised by the prosecutor and one time raising an objection sua sponte.  As Hohauser said, “you handled the judge perfectly.” Rockind never raised his voice to the judge and never let on how one-sided the judge appeared to be.   Rockind remained calm and continued undaunted.  After watching Rockind use the killer cross examination approach to examining the officer, a cross examination that will be shared here in full when the case is over, Hohauser had this to say about what he saw:

Yes I was Neil. It was classic. You brought it in perfectly. I was so busy watching you and the officer I didn’t notice if the jury was alert.

The cross examination was so compelling and the observer so drawn in, that his attention was focused on nothing else.  That is the best compliment that a trial attorney could receive from another trial attorney.

Neil Rockind (242)

Textbook Cross Of The Interrogating Detective | Several Lawyers Have Called This Cross “Brilliant” And Insisted On Publication

Sometimes, a cross examination of a witness flows so smoothly, is so powerful and so totally destroys the witness’s testimony that even the opposing side is left in awe.  Most lawyers never accomplish such a cross examination.  Some of the top lawyers, experience this feat several times.  The best of the best know this feeling well — this is the high bar that they set for themselves.  In a drug case that Rockind Law is still litigating, the prosecution called a witness to the stand to testify to our client’s supposedly incriminating and contradictory statements made during a police interrogation.   My cross examination was so compelling that one of the prosecutors when it was over, pulled me aside and paid me a compliment.  That same prosecutor same something similar in our last hearing.  When I said, “you weren’t smirking during that cross examination”, he responded and said, “No, I most certainly was not.”   My co-counsel in the case ordered the transcript and have repeatedly referred to it as a “masterpiece”, “masterful”, “best ever”, “textbook” and the “cross that young lawyers should have to read.”   I can’t tell you whether it was worth that amount of praise, but I remember it and I have to say, as an aficionado of cross examination, I appreciated my own work  on this one.

Take a look.  Take a read.  Let me know what you think.   Click on the Cross Examination Transcript to read the entire cross for yourself.

Rockind Textbook X Photo

Rockind Textbook X

Creating Something From Nothing | Killer Cross Examination

It happens many times.  I sit down and start reading through police reports in the case and the case looks bleak or there appear to be too few issues for us to challenge.  I look at the case from different angles and perspectives and still see very little.  This has happened to every lawyer.  Some admit it.  Some don’t.  However, it is at these moments that the great lawyers separate themselves from the pack — they create something from nothing.

Young lawyers want to know, when they reach these points:

What should they do?

How do good lawyers get past those points and moments?

How can they learn to do it?

These questions are not easily answered.  Some lawyers learn how to handle these situations and some don’t.  However, make no mistake about it … in these moments you must create something out of nothing.  You must look past the words on the page, imagine what was happening and taking place, imagine whether what the police claim they observed is in fact reliable or is what you imagined occurring more believable.  Make no mistake about it, I do not mean lie … I mean be creative:

“see what is there to be seen but that which is not obvious.”

Once you imagine a strategy, you’ve got to bring it to life and there is no surer way than by using a killer cross examination. Let me show you an example from a case that Rockind Law handled and won where the police reports seemed bleak but I saw what was there to be seen but that which was not obvious and then used a killer cross examination to bring it to life.

In this case, our client was caught with pounds of marijuana in a backpack in his car.  What was particularly troubling was that the cop claimed that our client made damning admissions during the traffic stop.  What’s worse?  The traffic stop and encounter was recorded and … our client did make damning admissions to the officer.   While our client was talking to the officer, he was not in handcuffs, was in his own car and was not told that he was under arrest.  It seemed like so many traffic stops and sad to say, our Supreme Court has already previously ruled that roadside questioning during a traffic stop does not ordinarily give rise to Miranda warnings.  Except when I watched the squad car video, I noticed that from the start, the officer ordered our client to keep his hands outside the window of his, an extremely unnatural position.  Worse, after playing and replaying the video, I captured one moment where the officer “threatened” our client with physical action if he moved his hands.  I decided to attempt to turn these facts into a claim that our client was “detained”, “in custody” and thus interrogated by the officer without the benefit of Miranda.  Take a read:

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Page 25


Page 26


Page 27


Page 28


Page 29

Notice how I took two (2) simple details, (1) the officer ordering our client’s hands to be outside of the car window and his not having access to his hands to do even the simplest things, e.g., rub an eye, scratch an itch, and (2) the officer’s threat (on video/audio) when our client started to gesture towards his bag, and weaved them into a comparison to “custody”, “the functional equivalent of being handcuffed” and his “freedom of movement being deprived in a significant way.”  As a result, the damning statements that came during that period of time were excluded as the product of “custodial interrogation” without Miranda warnings.

The next time that you’re struggling with a case, take a step back and think outside the box.  You have look past the words and see what is not easily seen or readily apparent.  Once you do, use a killer cross examination to bring that strategy to life.

About Neil Rockind

Neil Rockind is a criminal defense trial lawyer with Rockind Law, a Michigan law firm that handles only criminal defense cases.  Neil Rockind has been awarded nearly every award and honor given out to lawyers, including being named a Leader in the Law, a Super Lawyer, the Best of Detroit, a Leading Lawyer and among the Top 10 Criminal Defense lawyers in the state.  Neil Rockind is also the WDIV-TV legal expert commenting on legal issues and is often sought out for commentary by radio and newspaper reporters.  Both Neil Rockind and Colin Daniels, attorneys with Rockind Law, have been named Super Lawyers by Thomson Reuters.

Answer The Question

It has been too long since my last installment of killercrossexamination. I’m sorry about that. Lot’s going on…new website (, new award (Leader in the Law), television appearances (WDIV), etc.  Still, there is no excuse for not writing about my passion – great cross examination.  So here is a short but fun piece on “getting the cop to answer.”

I have many methods that I use to get the reluctant witness to answer. One of my favorites though is to ask the officer a simple question:

If you don’t want to answer my question just say ‘I don’t want to answer that question’

It focuses everyone’s attention on the evasiveness of the officer’s answers.  Here is an example where the officer didn’t want to admit that my client’s freedom of movement was deprived in a significant way, ie, the standard for custody.

Notice how he wouldn’t answer the question until I asked him simply, “if you don’t want to answer it, just say so.” At that point, he answers the question that he had been evading for nearly a page of testimony.

I have more to share on cross examination and many more transcripts to reveal.  However, I too long neglected updating this killer cross examination blog and wanted to take a moment to remind everyone that when it comes to cross examination, there is no better way than my way: killer cross examination.

About Neil Rockind
Neil Rockind had received nearly every accolade or honor as a criminal defense lawyer. He is the founder of Rockind Law, a criminal defense firm in Michigan. He is also the WDIV-TV legal expert commenting on law related issues and high profile cases.



Catching A Snitch (Jailhouse Informant) In A Lie

Jailjouse informants.  Every criminal defense lawyer in a major case in which his/her client is in custody in jail fears one of these low-lifes coming out of the woodwork.  These informants seek favor from the police and government by offering testimony against someone with a case pending.  They are sketchy, unreliable and unfortunately, dangerous witnesses.  Too often, juries rest guilty verdicts on these witnesses.  Too often lawyers do a poor job of cross examining these informants.  In the case of Mark Lundy, charged with murdering his wife and daughter, a jailhouse informant materialized out of thin air.   The witness claimed that Lundy said he would’ve got away with what he’d done, if his daughter hadn’t walked in and seen what he was doing to his wife.

The witness also claimed that Lundy told him he’d been planning what he did for some time, and “she had it coming to her”.  One part of Lundy’s lawyer’s cross examination of the informant caught our attention at

The informant testified that he met Lundy while they were in the segregation wing of a prison, in 2002.  He’s told the court he got chatting to Lundy while in the prison yard.  According to the informant, Lundy told him that he was waiting for an appeal to go through, but didn’t explain it.

Lundy’s lawyer seized on some information that he obtained from an investigation into the informant’s background, e.g., a probation report that referred to the informant as “manipulative” and aggressive when doesn’t get his own way.  The witness could hardly deny what was in the report.  And then, using the “manipulative” reference, the lawyer went to work on a glaring hole in the witness’s story:  that Lundy said he was on appeal while in the yard.  Why?  Lundy was not on appeal.  

Lundy’s lawyer, using a bit of killer cross examination, pulled some jail records and noted that the informant and Lundy were jailed together before his first trial and thus before any appeal.

“He wouldn’t have been waiting for an appeal because he hadn’t even been convicted,” he says.

Witness X replied, “he told me he was waiting for an appeal”.

Lundy’s lawyer then used the probation report to impeach the witness:

“Are you being manipulative again,” pressed Burns.

“No,” Witness X replied.

Meticulous attention to detail and a thorough investigation into the informant’s background is required in order to pull off a killer cross examination.  Some lawyers think that we just stide up to the podium or lectern in a courtroom and outwit the witness “off the cuff”.  They are wrong.  Conducting a killer cross examination requires skill, talent and wit, that is of course true, but it also requires something additional:  preparation.  Lundy’s lawyer likely neutralized this witness by obtaining information about the witness’ past, constructing a timeline and then reviewing that timeline against the facts.

Neil Rockind is a criminal defense lawyer with Rockind Law, a criminal defense trial firm in Southfield, Michigan.  Rockind has won virtually every award and accolade available to lawyers, including, Top Lawyer, Super Lawyer, Top 100, Top 50, Top 10, Leading Lawyer, Legals Finest and a Leader in the Law.  The Detroit Legal News referred to Rockind as “Tenacious”. characterized Rockind as someone who fights for the underdog.  Rockind is the Channel 4-WDIV (NBC) local television analyst/expert.  Rockind handles drug, alcohol related, white collar and assault type cases in and around the state of Michigan and in federal court.  He is the author of 

Straight Answers — The Line That Helped A Great Personal Injury Lawyer Depose A Tough Doctor

“Are you going to give me straight answers?”  A rather simple question, right?   Opposing experts in civil and criminal cases often do anything but give straight answers.  Long, twisted, curvy and evasive answers are what experts typically give to lawyers cross examining them.  How to tackle the problem?  A colleague of mine, Vince Colella of Moss & Colella, and, is one of the finest personal injury lawyers in Michigan.  He is so dedicated and talented, that he has been named a Super Lawyer, a prestigious honor bestowed on only the top 5% of all lawyers in Michigan.  Recently, Vince Colella approached me to discuss a trial deposition that he was preparing for involving a particularly feisty and difficult doctor.   The doctor was being called as an expert witness by the opposing side, the insurance company.  After a few minutes of discussion, I suggested starting the deposition with a simple question — one that would catch the expert off guard and unprepared:

Are you going to give me straight answers?

You see, depositions typically begin the same way:  lawyers asking background questions, questions about the expert’s experience, work, etc.  It provides the lawyer with information but it also gives the expert a chance to get in a groove, warm up and get comfortable.  Vince elected to take a different approach.  He elected, a few questions into the deposition, to pop the question:

Are you going to give me straight answers?

The goal being to confront the expert with that stark question.  We prepared for the expert’s possible responses.  If he hemmed and hawed, Vince could challenge him right then after all, why wouldn’t he agree to just give straight answers?  Vince even planned to write it out on a sheet paper, once the expert agreed.   Whenever the expert started to go sideways, he would ask the question again using the prior commitment:

I thought you were you going to give me straight answers?

He might even use the sheet of paper.  After a while, we figured, the expert would see Vince reaching for the sheet of paper and know that he was about to get whacked.  He left to put it into action.

After the deposition, Vince returned to the office and reported back how successful this simple tactic was.  Vince asked the expert the question, “Are you going to give me straight answers?” early in the deposition, earlier than expected, and the doctor responded:  “I’ll try.”   Vince told me that he smiled at hearing that — “why would one have to try to give straight answers,” he said he thought.   But he soldiered on and periodically, the expert would attempt to offer some rubbery answer to which, Vince asked:

I thought you were going to try to give me straight answers?

After only a few incidents of having to remind the expert about his commitment to try and give straight answers, Vince relayed that the expert was controllable and manageable and that the deposition not only didn’t hurt Vince’s case but actually helped.

Sometimes doing the unorthodox or unconventional makes all the difference in the world.  This time Vince delivered a killer cross examination with one question:

Are you going to give me straight answers?

About Vince Colella

Vince Colella is a personal injury, civil rights attorney and plaintiff’s attorney representing individuals who have been injured in automobile accidents, personal injury cases and/or who have been sexually harassed or discriminated against at work.  Colella has been named a Super Lawyer in the area of plaintiff’s personal injury cases and has garnered millions of dollars in awards for clients and their families over the years.   To find out more about him, visit

About Rockind Law

Rockind Law is a Southfield, Michigan-based criminal defense law firm aggressively pursuing justice for individuals facing criminal charges, including white collar crime, drunk driving, narcotics and assault. To find out more about the firm’s services and resources, visit

About Neil Rockind

Neil Rockind is a criminal defense lawyer with offices in Southfield, Michigan.  Rockind has been named a Super Lawyer, among the Top 100 Lawyers in Michigan, among the Top 50 Lawyers in Michigan, among the Top 10 Criminal Defense Lawyers in Michigan, among the Top 100 DUI Attorneys in the United States, the Best of Detroit by Hour Magazine, a Top Criminal Defense Lawyer by Dbusiness Magazine and among the Top 100 Trial Lawyers by the National Trial Lawyers Association.  He has lectured and taught trial tactics and strategies to other lawyers and is frequent guest in the media discussing legal issues and current events.  Rockind is also the WDIV Legal Expert.


The Case Of The Illegible Handwriting – A Killer Cross Examination That Resurrected An Under Advisement Sentence For A Client

Read the story and excerpts about how we saved a young man from a probation violation and got a judge to give him an under advisement plea, i.e., MCL 333.7411, after she had originally denied it.  A killer cross examination saved the day.  Here’s the story:

A young man who chose to handle his case without our assistance found himself placed on probation by a local district court judge.  He left the court, went to a clerk’s window and then left the building with plans to appear for a probation meeting the following Monday.  He showed on Monday, met with a probation officer for the first time and was asked a single question that would require him to appear again in court for a probation violation hearing:  “how did you get to the courthouse today?”  When he answered, “I drove,” the probation officer advised him that he was prohibited from driving and that his license was suspended.  The young man was stunned.  He left and contacted our office.  We ordered the transcript from the sentencing hearing and obtained copies of the “Sentence Order.”  Here is a copy of the pertinent part of the “Sentence Order” — the probation officer claimed that the handwriting at the bottom of the form, writing that had never been explained to the young man, put him on notice about his license being suspended:


Miller Sentence Order

Our defense at the hearing was that he did not know that his license was suspended and that his license was not suspended.  After reviewing the transcript and line number 37, we even decided to argue that his application for MCL 333.7411, the under advisement statute, had not been denied as the Court maintained.

The witness, the probation officer, attempted to tow the proverbial party line as much as is possible.  She proved to be a resistant, difficult witness that tried to repeatedly argue with me and use the judge as a backdrop or safety valve.  At one point, she attempted to claim that our client had received a copy of the Order of Probation and Sentence Order together.  She would not concede this simple point that Sentence Order was not attached to the Order of Probation even though the Order of Probation referenced a “Sentence Order Attached.”  Worse, she attempted to rely on “practice and procedure” rather than actual facts.  On this one issue, whether the order was attached to the Order of Probation, here is a sample of how I dealt with her difficulty:

miller sentence order cross

Miller Sentence order cross 2

In order to challenge the claim that he knowingly violated his probation, I needed to undermine the claim that he had been told of the condition prohibiting driving and then I needed to challenge the claim that the handwriting put him on notice.

I began a challenge that would poke and point out how illegible handwriting on the Order actually was.  

Miller 7411

This was the order that contained the handwriting that I was challenging.  Here was was my first challenge:

miller question mark crsos


My attack on the legibility of the handwriting on the Order continued with a discussion about the words next to community service hours.  Here is the Order:

miller fines handwriting order


It looked like “zoo” to me so I didn’t shy away from cross examining on what appeared to be written in that space.  Here is the cross:

Miller fines cross

Miller fines cross 2

The Order contained some words that were illegible regarding drugs.  It said “no drugs” and than what looked a couple of scribbles and the word “rumor”.  Here is the Order:

Miller No Drugs Order



I cross examined on the illegibility of the handwriting and started laying the foundation for how the probation officer was relaying on the her familiarity with the judge’s handwriting, something that our client did not have.  Take a read:


Miller No Drugs Cross

Miller no drugs cross 2

 My cross examination was leading up to the primary issue, the language on the bottom of the order but I could not resist a shot at the Order and what it said about MCL 333.7411.  Did the Order say that MCL 333.7411 was “okayed” or “denied”.  Here was the Order:

Miller deny 7411

I cross examined the probation officer on the what the word was next to the “/”, was it “okay” or a “deny?”   You’ll see that the judge tried to interject and “testify” and accused me of testifying to which I responded, “this is cross examination”:

Miller 7411 deny cross

Miller 7411 cross 2

Having made a challenge to the legibility of the language on the Sentence Order, I proceeded to the language that was at the heart of the allegation of a violation of probation, i.e., the language that supposedly indicated that the accused’s license was suspended.  What was written here?  The first word looked like “Liz” … Here is the Order:
Miller Sentence Order

My cross on the handwriting follows:

miller license susp cross

Miller license susp cross 2

I then closed in … I questioned about a review of the transcript to discover 1) what was actually said to the client and 2) what was on the Sentencing Order since the handwriting was to put it generously, ambiguous:

Miller license susp cross 4


Of course, the probation officer had not reviewed the transcript.  Had she reviewed it, she would have learned that the judge never mentioned license sanctions on the record.   But, she tried to stick with the handwriting on the “Sentence Order”, i.e., she walked right into our trap.  Read on:

Miller license susp cross 5


Or course it was clear to her, she works in the probation department, is familiar with the terminology and the judge’s handwriting.  The accused was not:

Miller license susp cross 6

Miller license susp cross 3

In the end, the transcript did not provide the probation officer with support and the sentencing order proved to be unreliable in terms of notice.  While perhaps the probation officer was aware of what the judge wrote or meant because she had seen 100’s of these orders and knew the judge’s handwriting, our client had not.  He was a novice.  A killer cross examination exposed his lack of notice and awareness that his license was suspended and ultimately ended up persuading the judge to give him what she claimed she had originally denied him, MCL 333.7411.

A Study About Cross Examination – Cross Can Impact Jurors

How do leading cross-examination questions influence jurors’ perceptions of experts?

Because of the nearly unrestricted use of leading questions, cross-examination provides opportunity to influence jurors through questions designed to impart information to the jury.

Kassin and colleagues (1990) tested whether jurors’ perceptions of an expert witness can be influenced by leading cross-examination questions. Jurors heard a cross-examiner ask two questions of an expert witness that implied something negative about the reputation of that expert (Isn’t it true that your work is poorly regarded by your colleagues? Hasn’t your work been sharply criticized in the past?). One third of these jurors also heard a denial from the expert (No, it isn’t; No, it hasn’t), one third heard an admission from the expert (Yes, it has; Yes), and one-third heard objections to the questions from an attorney that were sustained by the judge and then withdrawn before the witness had a chance to respond. There was also a group of jurors who did not hear the leading cross-examination questions.

The expert’s credibility – that is, the expert’s honesty, believability, competence and persuasiveness – was significantly diminished by the leading questions. The expert was less credible to jurors even when the expert flatly denied the charge or the attorney won a favorable ruling on an objection.

The researchers concluded that the technique of cross-examination by innuendo is highly effective in diminishing an expert’s credibility, and that both an attorney’s objections and an expert’s denials of the innuendo fall on deaf ears.

From the OJRU Blawg at

Source Kassin, S. M., Williams, L. N., & Saunders, C. L. (1990). Dirty tricks of cross-examination. Law & Human Behavior, 14, pp. 373-384.

An Excerpt Of A Cross Examination Of A Witness Cooperating With The Prosecution

The cooperating witness has many names:  cooperator, informer, snitch, turncoat, benedict arnold, betrayer, etc.  Many lawyers are afraid to confront the cooperating witness.  A killer cross examination is necessary to undermine the reliability of the witness and at the same time, undermine the prosecution’s case.

A young lady referred to two local judges in a very derogatory fashion.  I had a tape recording of a conversation in which she had made this reference — it was a reference that was unlikely to be uttered or heard in the middle of a drunk driving case, but it turns out that it was one of the elements of a killer cross examination that helped obtain an acquittal for our client.  The case, one of the hardest that I have tried, involved the “switching seats” defense:  the claim that our client (the passenger) switched seats with the driver during the traffic stop in an effort to throw off the police.  The two were cousins.  Our client claimed to have switched seats.  When she was charged and prosecuted, she expected her cousin to come forward and tell the truth and free our client.  It did not go down that way.  Unfortunately, her cousin abandoned her.  Worse, her cousin turned on her and actually attempted to testify that she was only the passenger and that our client was indeed the driver.  The cousin was “cooperating with the prosecution.”  A killer cross examination was needed.  I delivered one.

This excerpt is a small part of the cross examination of the informant/cooperating witness in this case.  I will reveal more excerpts over the succeeding days and weeks.  Of course, you’re wondering how the derogatory reference became a part of a drunk driving trial?  Well … The witness and our client had talked on the phone about the case.  The phone call was tape recorded.  At one point, the pair discussed their judges (the cousin had an MIP).  The cousin stated that “they both sound like whores.”   A killer cross examination involves the use of wit and positioning of witnesses and so we positioned the witness to use this offensive quote.  I questioned her about respecting others and the Court.  She stated that she respected everyone, especially the Court.

Do you think that  referring to a judge as a “whore” is a sign of respect?

Read on for this and more of my cross examination of a cooperating witness in this case.

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